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NY C89835

July 31, 1998

CLA-2-85:RR:NC:MM:101 C89835


TARIFF NO.: 8511.80.6000

Mr. Robert Resetar

Customs Manager

Porsche Cars North America, Inc.

980 Hammond Drive

Suite 1000

Atlanta, Georgia 30328

RE: The tariff classification of an Automotive Ignition Control Unit (Capacitative Discharge System)from Germany

Dear Mr. Resetar:

In your letter dated June 29, 1998 you requested a tariff classification ruling.

The item is a capacitative discharge ignition control unit also known as a CDS Unit.

This unit is an alternative to the conventional induction coil system. The electronic components of the system are contained in the CDS unit.

The light alloy housing of the CDS unit is provided with cooling fins to help dissipate heat generated by the system. An ignition voltage transformer takes the place of the conventional induction coil. The transformer is similar in construction to a coil yet differs considerably. For example; resistance, voltage gain ration and inductivity match the specific electrical characteristics of the CDS unit.

When the ignition is turned on, the DC converter steps up the battery voltage from 12 volts to 450 volts, charging the storage capacitor. This charging is brought about through periodic impulses at a frequency of approximately 3,00 Hz; this produces a high a pitch whistling sound in the DC converter. When the breaker points open, the ignition trigger unit releases an impulse to the thyristor base. The thyristor becomes conductive. The charge in the storage capacitor then discharges through the thyristor and ignition voltage transformer. This causes a high voltage surge on the secondary side which is carried through the distributor to the spark plug. In the CDS, ignition voltage rise at the spark plug occurs much faster than in the induction coil ignition.

The applicable subheading for the CDS unit will be 8511.80.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical ignition or starting equipment of a kind used for spark-ignition or compression-
ignition internal combustion engines (for example, ignition magnetos, magneto-dynamos, ignition coils, spark plugs and glow plugs, starter motors); generators (for example, dynamos, alternators) and cut-outs of a kind used in conjunction with such engines; parts thereof:...Other equipment...other. The rate of duty will be 2.6 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Robert DeSoucey at 212-466-5667.


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